Indictment — United States v. John Doe (D. Mass., Dkt. 1, filed 06/23/20)

Summary

Indictment, Case 1:20-cr-10118, Document 1, filed 06/23/20 (D. Mass.), against the defendant JOHN DOE. Count One charges False Representation of Social Security Number under Title 42, United States Code, Section 408(a)(7)(B), on an application for a Massachusetts identification card on or about August 14, 2017. Count Two charges Aggravated Identity Theft under Title 18, United States Code, Section 1028A(a)(1), on or about the same date. Count Three charges False Statement Relating to Health Care Matters, Aiding and Abetting, involving MassHealth, on or about August 3, 2015. A Forfeiture Allegation under Title 18, United States Code, Section 982(a)(7) follows Count Three, and the page ends with "A TRUE BILL".

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Case 1:20-cr-10118-WGY Document1 Filed 06/23/20 Page 1of5

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

Criminal No, 29cr10118

UNITED STATES OF AMERICA

Violations:
Count One: False Representation of
Social Security Number

(42 U.S.C. § 408(a)(7)(B))

JOHN DOE,

Defendant
Count Two: Aggravated Identity Theft
(18 U.S.C. § 1028A(a)(1))

Count Three: False Statement Relating to Health
Care Matters; Aiding and Abetting
(18 U.S.C. §§ 1035(a)(2) and 2)

Forfeiture Allegation:
(18 U.S.C. § 982(a)(7))

INDICTMENT

COUNT ONE
False Representation of Social Security Number
(42 U.S.C. § 408(a)(7)(B))
The Grand Jury charges:

On or about August 14, 2017, in Lawrence, in the District of Massachusetts, the defendant,

JOHN DOE,
for the purpose of obtaining anything of value from any person, and for any other purpose, did,
with intent to deceive, falsely represent a number to be the social security account number assigned
by the Commissioner of Social Security to him on an application for a Massachusetts identification
card, when in fact such number is not the social security account number assigned by the

Commissioner of Social Security to him.

All in violation of Title 42, United States Code, Section 408(a)(7)(B).

l
Case 1:20-cr-10118-WGY Document1 Filed 06/23/20 Page 2 of 5

COUNT TWO
Aggravated Identity Theft
(18 U.S.C. § 1028A(a)(1))
The Grand Jury further charges:
On or about August 14, 2017, in Lawrence, in the District of Massachusetts, the defendant,
JOHN DOE,
did knowingly transfer, possess, and use, without lawful authority, a means of identification of
another person during and in relation to a felony violation enumerated in Title 18, United States
Code, Section 1028A(c), that is, False Representation of Social Security Number, in violation of

Title 42, United States Code, Section 408(a)(7)(B), as charged in Count One.

All in violation of Title 18, United States Code, Section 1028A(a)(1).
Case 1:20-cr-10118-WGY Document1 Filed 06/23/20 Page 3 of 5

COUNT THREE
False Statement Relating to Health Care Matters; Aiding and Abetting
(18 U.S.C. §§ 1035(a)(2) and 2)

The Grand Jury further charges:

On or about August 3, 2015, in the District of Massachusetts, the defendant,

JOHN DOE,

knowingly and willfully made a materially false, fictitious, and fraudulent statement and
representation, that is, that his name was that of a person with the initials E.E.R.C., in connection
with the delivery of and payment for health care benefits, items, and services involving
MassHealth, a health care benefit program as defined in Title 18, United States Code, Section
24(b).

All in violation of Title 18, United States Code, Sections 1035(a)(2) and 2.
Case 1:20-cr-10118-WGY Document1 Filed 06/23/20 Page 4of5

FORFEITURE ALLEGATION
(18 U.S.C. § 982(a)(7))

L, Upon conviction of the offense in violation of Title 18, United States Code,
Section 1035, set forth in Count Three, the defendant,
JOHN DOE,
shall forfeit to the United States, pursuant to Title 18, United States Code, Section 982(a)(7), any
property, real or personal, that constitutes or is derived, directly or indirectly, from gross
proceeds traceable to the commission of the offense.
2. If any of the property described in Paragraph 1, above, as being forfeitable

pursuant to Title 18, United States Code, Section 982(a)(7), as a result of any act or omission of

the defendant —
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
C, has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
S. has been commingled with other property which cannot be divided

without difficulty;
it is the intention of the United States, pursuant to Title 18, United States Code, Section 982(b),
incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any other
property of the defendant up to the value of the property described in Paragraph | above.

All pursuant to Title 18, United States Code, Section 982(a)(7).
Case 1:20-cr-10118-WGY Document1 Filed 06/23/20 Page 5of5

A TRUE BILL

WILLIAM F.
ASSISTANT UNITED STATES ATTORNEY
DISTRICT OF MASSACHUSETTS

District of Massachusetts: JUNE2% _, 2020
Returned into the District Court by the Grand Jurors and filed.

Dawn M. King 2:35pm
DEPUTY CLERK


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